Developments in the Pension Sector - Pension Sector Overview 2026

ANALYSIS REPORT Pension Sector Overview 2026 In Brief - With this publication, the AFM shares insights into key developments in the pension market, derived from reports submitted by pension administrators. The publication enables pension administrators and social partners to compare the characteristics of their own scheme and the choice options available to participants with the rest of the sector. In particular, we focus on three main topics: the characteristics of the premium schemes of the first participants in the new pension system, the current status of the group of participants who are building up little or no pension, the insights we derive from our complaint survey, and how investment freedom is implemented in premium schemes. This sector overview is based on 2024 data provided by the pension sector. MAY | 2026

© AFM 2026 | Pension Sector Overview 2026 2 Table of Contents Introduction 3

1. Significant differences exist in what participants in premium schemes can expect from their pension 1.1 Flat premiums are easy to compare and indicate pension prospects 4 1.2 The group of employees building up a pension has grown due to the lowered starting age 6 1.3 Partner pensions and premium continuation in case of disability are increasingly insured 6 1.4 However, data on the new system also shows that partner pension coverage can vary significantly 7
2. Complaint data provides a valuable perspective on service quality 2.1 The number of registered complaints varies by type of pension administrator 9 2.2 Most registered complaints concern pension calculation and payment 10 2.3 By far the majority of complaints are resolved within a few weeks 11
3. Investment freedom does not everywhere lead to actual choice, especially young participants lag behind 3.1 The majority of participants in premium schemes have investment freedom 12 3.2 Low use of investment freedom, especially among young participants 13 3.3 Large differences in the use of investment freedom between pension administrators 14
4. Appendix – General 4.1 Number of pension administrators 15 4.2 Participants in the accrual phase 15 4.3 Types of pension agreements 16 4.4 Value of pension accrual in the Netherlands 17 4.5 Benefit phase 18
5. Appendix – Benefit agreements 5.1 Accelerating and postponing pension commencement 19 5.2 Varying benefit amounts 19 5.3 Partner pension and premium exemption 20 5.4 Restrictions on pension accrual 21 5.5 Pension at the end of the term 21
6. Appendix – Premium agreements 6.1 Defined/Variable pension 22 6.2 Accelerating and postponing pension commencement 23 6.3 Varying benefit amounts 23 6.4 Investment freedom 24 6.5 Partner pension and premium exemption 25 6.6 Restrictions on pension accrual 26 6.7 Pension at the end of the term 27

© AFM 2026 | Pension Sector Overview 2026 3 Introduction The Dutch pension sector is in the midst of a transition. Previously, 75% of active participants in the second pillar built up a pension in a benefit scheme. After the transition, everyone will build up a pension in a premium scheme, where the amount of contributions is fixed, but the benefit amount depends on market conditions. This means the pension transition is not only impactful for the pension sector, but especially for the pension participant. Many are facing a different pension scheme, where risks and opportunities now lie more directly with themselves. What do these changes mean in practice? How do pension schemes differ from each other now, and what do the first figures say about the consequences for participants? This report offers a unique perspective on these questions from the standpoint of behavioral supervision by the AFM, based on the reporting year 2024 of the Supervisory Report Second Pillar Pensions.1

With this report, we aim to contribute to a better-substantiated picture of trends and points of attention in the pension sector. By combining our data with analysis and interpretation, this report supports pension administrators, social partners, policymakers, and execution organizations in making choices in a system that is in constant motion. This publication contains an extensive statistical appendix, allowing readers to track the development of certain aspects over time. The appendix consists of three parts: general insights, benefit schemes, and premium schemes. The graphs in the appendix largely correspond to earlier publications. Using data, we make visible how pension schemes are developing in the new system. By the end of 2024, there were seven pension administrators with participants in the new pension system, and these were exclusively pension insurers and PPIs. This concerned a small group of approximately 75,000 participants (active and former). The first pension funds only entered the new pension system on January 1, 2025. As a result, by the end of 2024, no one was participating in a solidarity premium scheme. The picture of the new pension system will become sharper each year as more pension schemes are converted. In the first chapters of the publication, we also highlight three topics that stood out to us in the data. These are (1) the significant differences in what participants in premium schemes can expect from their pension, (2) the perspective that complaint data provides on the quality of service by pension administrators, and (3) the limited share of participants who make use of the opportunity to make choices about their pension investments. More information? You can find more information about the AFM and the Supervisory Report Second Pillar Pensions on the AFM website. The website also contains a more extensive explanation of the various topics covered in this Pension Sector Overview, including an overview of our earlier publications. 1 This publication is based on the reports that Dutch pension administrators have submitted to the AFM as of the reference date December 31, 2024. All Dutch pension funds, pension insurers, and premium pension institutions report annually to the AFM via the Supervisory Report Second Pillar Pensions. The AFM also uses the data from the Supervisory Report Second Pillar Pensions to monitor the most important trends and developments in the pension sector and to maintain risk-based supervision. Based on this data, we quantify risks and prioritize themes for our supervision. The data as of the end of 2024 is the most recent data available at the time of this publication; pension administrators must submit reports for the reference date December 31, 2025 by September 30, 2026 at the latest.

© AFM 2026 | Pension Sector Overview 2026 4

1. Significant differences exist in what participants in premium schemes can expect from their pension Participation in a second-pillar pension scheme determines, alongside the state pension (AOW), the income after retirement to a large extent. Employees in wage employment who do not participate in a pension scheme are also referred to as the 'white spot'. Next to the white spot, the term 'grey spot' is used to refer to the group of participants in pension schemes who are building up a (very) small pension. This group is not clearly defined, as what constitutes an adequate pension can vary by sector and participant population. For this reason, we track the development of this group from various angles. 1.1 Flat premiums are easy to compare and indicate pension prospects In a premium scheme, the premium amount is fixed and the pension benefit amount depends on market conditions such as investment returns and interest rates. This makes it easier to compare the quality of premium schemes for individual participants based on the premium than with collective benefit schemes, where redistribution often occurs. The new pension system works with flat premium percentages, which are the same for all ages. This makes it easier to compare the premium level of a younger and older participant than in the old situation, where the premium increased with age according to a predetermined premium scale. As an illustration: a look at the small first group of participants in the new system shows that the level of the flat premium can vary strongly between pension schemes. Despite the still limited size of the group of active participants in the new pension system, the data provides a first picture of the level of the flat pension premium. For 12% of these participants, the premium percentage is 5% or less, and for 7% it is 20% or more. This picture will change in the coming years as more participants transition to the new pension system. In particular, for benefit agreements that transition to the new system, social partners have agreed on higher premium percentages. Figure 1: Percentage of participants split by premium percentage for schemes in the new system What does Figure 1 show? The graph shows the distribution of participants in the new system by the level of the premium percentage in their pension scheme. For 7% of participants, the premium is 20% or more of the pension base, for 47% of participants the premium is between 11% and 20%, for 34% of participants the premium is between 6% and 10%, and for 12% of participants the premium is 5% or less. 12% 47% 34% 7% More than 20% premium 11% up to and including 20% 6% up to and including 10% 5% or less premium

© AFM 2026 | Pension Sector Overview 2026 5 The limited utilization of fiscal space for pension accrual is a broader issue among participants in premium schemes. On average, the pension scheme utilizes 42% of the fiscal space for the 1.8 million participants in premium schemes. In the context of the new pension system with a maximum flat premium of 30%, a utilization of 42% would be equivalent to a flat premium of just under 13%. As indicated earlier, this picture will change when more benefit agreements are transferred to the new system; we will update these statistics then. How much pension do different flat premium percentages ultimately yield? To get a feel for the impact on pension income, we have included an indication in Figure 2. For this simplified estimate, we assume that a flat premium of 30% of the pension base at an interest rate of 1.5% leads to a pension of 75% of the average wage. We make this assumption because the interest rate of 1.5% was the basis for the maximum flat premium scale of 30%, which is intended to yield a comparable pension as an average wage scheme with an annual accrual rate of 1.875%. Over the entire career, that average wage scheme results in a pension of 75% of the average wage (including AOW). This is generally considered adequate, as expenses and taxes are lower after retirement than during working life. The level of interest rates has a major influence on the expected pension level. As an example, we highlight a flat premium of 10% of the pension base, which we see in Figure 1 is common. This premium level results in the example at an assumed interest rate of 1.5% in a pension of 46% of the average wage. But at an interest rate of 3% - closer to the current interest level - that rises significantly to 58% of the average wage. But at a premium level of 5%, the pension scheme in the example also results in the more positive scenario with 3% assumed interest in a pension of 45% of the average wage, which then consists of more than two-thirds AOW. Figure 2: Estimate of the replacement ratio at different flat premium percentages What does Figure 2 show? The graph gives an indication of the replacement ratio at different flat premiums and interest rates. The light blue line shows the AOW of €19,172, which at an assumed average wage of €50,000 offers a replacement ratio of 32%. The dark purple line shows the replacement ratio at different premium percentages at an interest rate of 1.5%, and the light purple shows the same at an interest rate of 3%. We assumed that the replacement ratio at 30% premium and 1.5% interest is equal to 75% of the average wage. At a lower premium, the replacement ratio decreases linearly to the AOW level of 32%. The AFM sees the risk that participants with low pension accrual assume their supplementary pension via their employer is well arranged, while the accrual is limited. Therefore, we call on the sector to ensure participants have realistic expectations of their pension scheme, for example in our 2023 report. This can be done in multiple ways, for example by informing participants well. Participants can then take any necessary measures in time to prevent financial problems after retirement. 0% 5% 10% 15% 20% 25% 30% 0% 30% 45% 60% 75% At 3% interest At 1.5% interest AOW Percentage of average wage Premium percentage

© AFM 2026 | Pension Sector Overview 2026 6 1.2 The group of employees building up a pension has grown due to the lowered starting age As of January 1, 2024, the minimum starting age for pension accrual in the Netherlands was lowered from 21 to 18 years. As part of the Pension Agreement, the government, social partners, and the pension sector agreed to strive to halve the white spot (wage employees who do not participate in a pension scheme) from 936,000 in 2019 to 468,000 in 2027. Part of this is the lowering of the starting age for pension accrual, which ensures that young people start building up a pension earlier. This has indeed led to an increase in the number of active participants. In general terms, we see that the number of active participants has been increasing for several years. In our data, the increase in the number of active participants at sector pension funds stands out in particular between 2023 and 2024. The 43 sector pension funds had over 286,000 more active participants by the end of 2024 than at the end of 2023. Of these, 247,000 are accounted for by the ten largest sector pension funds. Figure 3: Number of active participants (in millions) What does Figure 3 show? The graph shows the development of the number of active participants at sector pension funds from 2022 to 2024 in relation to the total number of active participants. In 2023, sector pension funds had a total of 5.84 million active participants, in 2024 this had risen to 6.12 million. The increase amounts to 286,000 participants. 1.3 Partner pensions and premium continuation in case of disability are increasingly insured For an increasingly large share of participants in premium agreements, there is coverage in the event of death before the pension date or in case of disability. Between the end of 2022 and the end of 2024, the share of active registrations (one participant can have multiple pensions or registrations) without partner pension coverage was halved. The group of participants without coverage for the continuation of pension accrual in case of disability (PVI) is also much smaller in 2024 than in 2022. The AFM welcomes this development and calls on administrators to proactively inform participants for whom no risk coverage applies. Both to prevent disappointment and to enable them to take out other insurance in time to protect against a drop in household income in the event of death or a pension gap in case of disability. 8,20 5,59 1,85 5,84 2,02 6,12 2,08 7,45 7,86 Sector pension funds Other pension administrators

© AFM 2026 | Pension Sector Overview 2026 7 Figure 4: Risk coverage of active participants within premium agreements What does Figure 4 show? The graph shows per reporting year (2022–2024) the share of active participants without risk coverage, split by the lack of partner pension coverage and the lack of PVI coverage. The share of participants without partner pension coverage has decreased from 19% in 2022 to 15% in 2023 and 9% in 2024. The share of participants without PVI coverage has decreased from 17% in 2022 to 15% in 2023 and 12% in 2024. 1.4 However, data on the new system also shows that partner pension coverage can vary significantly Partner pension coverage varies strongly per pension scheme in the new system. The 2024 reporting data gives a first picture of the level of partner pension coverage agreed upon by social partners within the pension schemes in the new system. Only a small portion of active participants have coverage close to the maximum. For the majority of participants, the coverage is lower than 30% of the pensionable salary, and for a small portion, the coverage is even lower than 20% of the pensionable salary. At such low coverage, household income can drop significantly in the event of death before the pension date. If participants are well aware of this, they can make other provisions. Figure 5: Share of active participants per category of partner pension coverage relative to pensionable salary What does Figure 5 show? The graph shows the distribution of participants in the new system by the level of partner pension coverage in their pension scheme, expressed as a percentage of the pensionable salary. For 18% of participants, the coverage is 41% or more, for 23% of participants the coverage is between 31% and 40%, for 49% of participants the coverage is between 21% and 30%, and for 10% of participants the coverage is 20% or less. 2022 2023 2024 19% 17% 15% 15% 9% 12% No partner pension coverage No PVI coverage 10% 23% 49% 18% 20% or less 21% up to 30% 31% up to 40% 41% up to 50% Partner pension coverage relative to pensionable salary

© AFM 2026 | Pension Sector Overview 2026 8 Informing well about risks in the new partner pension With the introduction of the new pension system, the design of the survivor pension changes. In the event of death before the pension date, the partner pension will from now on be arranged on a risk basis by default, with a maximum benefit of 50% of the pensionable salary. Because the new survivor pension is on a risk basis, coverage stops if the participant leaves employment and no longer participates in the pension scheme, after the expiration of the mandatory run-off coverage and any optional continuation. With the changes to the survivor pension taking place through the Wtp, new risks and communication challenges also arise. During the transition to the new pension system, participants can, for example, become uninsured without realizing it. On our website, we have included a number of situations where you need to be extra alert to timely and clear communication, to provide participants with sufficient perspective for action in these situations.

© AFM 2026 | Pension Sector Overview 2026 9 2. Complaint data provides a valuable perspective on the quality of the service 2.1 The number of registered complaints varies by type of pension administrator Pension funds register relatively more complaints per participant than PPIs. In absolute numbers, no less than 99% of all complaints in 2024 came from participants of pension funds, compared to only 1% at PPIs.2 Within pension funds, occupational pension funds report the most complaints per participant, and sector pension funds report the fewest. Since the new statutory requirements for adequate handling of complaints have been in force since July 1, 2023, 2024 is the first full year for which the AFM has data on complaints at pension funds and PPIs. Figure 6: Average number of registered complaints per 10,000 participants What does Figure 6 show? The graphs show the average number of registered complaints per 10,000 participants, split by type of pension administrator (pension fund or PPI, left) and type of pension fund (occupational, enterprise, general, or sector pension fund, left). We have plotted the number of complaints against the number of active participants (dark purple) and the total number of participants (light purple). A low number of registered complaints is not automatically positive. A high number of complaints can indicate problems in service delivery. This could, for example, concern experienced shortcomings in service quality, compliance with rules, or interaction with participants. But a low number of complaints can also be a signal that something is not going well. Participants may not know well how to submit a complaint or experience barriers to doing so (see also: Towards a complaint procedure without barriers). It is important that all expressions falling within the statutory definition of a complaint are registered as such. Participants have the right to treatment via the complaint procedure. And to subsequently go to the dispute settlement body if their complaint (partially) is rejected. 2 For pension insurers, this part of the reporting is not mandatory. They already report annually on complaints to the AFM via the Complaint Survey for Insurers. The data from insurers who did report on complaints is not included in this Sector Overview, as this would otherwise give an incomplete picture. PPI Per 10,000 active Per 10,000 participants Pension fund 93 82 47 29 43 22 12 10 Occupational pf. Enterprise pf. General pf. Sector pf. 33 3 12 1

© AFM 2026 | Pension Sector Overview 2026 10 2.2 Most registered complaints concern pension calculation and payment In 2024, pension funds and PPIs registered a total of over 23,000 complaints. The complaints are classified into one of a total of twelve categories as included in the code of conduct 'Good Handling of Complaints' of the Pension Federation. Most complaints concerned pension calculation and payment, the financial situation of the fund (such as reductions, non-indexation, and investment policy), and information provision. Together, these three categories account for nearly two-thirds of all complaints. Figure 7: Number of reported and handled complaints (in thousands) What does Figure 7 show? The graphs show the three most common categories of the 23,000 reported complaints (left) and the different outcomes assigned to the 22,000 handled complaints (right). Complaints can relate to multiple categories; a mistake in pension calculation, for example, often also coincides with incorrect information to participants. The graph includes the main category of the complaint entered by the pension administrator. Approximately 60% of the complaints (13,000) were rejected. Complaints about handling duration and the participant portal are often assigned. When a pension administrator offers a participant portal, the AFM calls on them to ensure it functions well, especially if the portal forms the basis for interaction with participants. Poorly functioning portals can lead to confusion, incorrect or incomplete information, or missed choice moments. In general vi